submission - Independent Pilots Association

similar language is contained in Sections I35.265 (b) and
(c). Also note the "l-ook back" requirement in Section
r35.267 (d) .
The EAA has consistently interpreted Section L2I.471(b)
and the correspondinq Section I35.265(b) to mean that the
certificate holder and the flight crewmember must be able to
look back over the 24 consecutive hours preceding the
scheduled completion of the flight segment and find the
required scheduled rest period. This interpretation of rest
also has been applied to pilots On "reserve time." Reserve
time wh1le not defined in 14 CFR 1s general-Iy understood to
be a period of time when a ffight crewmember is not on duty
but must b'e available to report upon notice for a duty
period. Thus, a flight crewmember on reserve could not take
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d I-LIL¡llL ^Lr- crD>JVIIItLvllLt --oi ¡¡1¡p¡1_ _ ancl arru the ur CertifiCate hOlder COufd nOt
schedule that crewmember for a flight assignment, unless the
flight crewmember had a scheduled rest period such that at
the end of the fliqht segment one could fook back 24 hours
and find the required amount of rest.
Compliance and Enforce¡nent PIan
Flight crewmembers and their unions have raised
Concerns that scheduling procesSeS used by Some certificate
holders may not ensure compliance wíth flight time
restrictions and rest requirements when a ftight crewmember